CMS Continues to Transition the Quality Payment Program Towards MVPs in 2025

In its 2025 QPP regulations the CMS will:

• Leave the performance threshold to 75 points for 2025, which the CAP continues to believe represents a significant burden on pathologists.
• Maintain the data completeness threshold at 75 points for 2025, a previously finalized policy.
• Not add or remove any measures from the Pathology Specialty Measure Set.
• Reduce the available options for Improvement Activities, including several IAs that are commonly performed by pathologists.
• The CMS continues to implement MIPS Value Pathways (MVPs) and for the first time, has included two pathology quality measures in a new proposed MVP: Dermatological Care.
  • Participants need at least 4 quality measures to report an MVP.
  • CMS has stated that denominator reduction mechanisms will not apply to MVPs so single-specialty pathology groups cannot report the Dermatological Care MVP as currently constructed.
  • The CAP responded to CMS’ request for input on developing MVPs for non-patient-facing specialties noting that the current iteration of MVPs may not meaningfully capture pathologists and requesting that CMS maintain traditional MIPS.
  • The CAP also responded to CMS’ request for information regarding developing of an Innovation Center model for specialists from an MVP, noting that all models should be voluntary and that there are still too many unknown factors to support converting an MVP into an APM.

The CAP continues to advocate for pathologists’ success in the MIPS program. We encourage practices (and their billing companies) to review the scoring changes and contact CAP at mips@cap.org to understand the availability of higher-scoring measures and how to best report them.

Advanced Alternative Payment Models (APMs)

For the Advanced APM track, if an eligible clinician participates in an Advanced APM and achieves Qualifying APM Participant (QP) or Partial QP status, they are excluded from the MIPS reporting requirements and payment adjustment. According to CMS, the agency continues to pursue “driving higher value care, supporting Advanced APM participation, increasing alignment to reduce burden, and promoting health equity.” In this final rule, the CMS published changes to the definition of “attribution-eligible beneficiary” for purposes of QP determinations. The rule also incorporates changes made by Congress to continue the APM Incentive Payment amount for the 2026 payment year (performance year 2024) of 1.88%.